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International Journal of Law And Criminology

Peer Reviewed | Open Access | E-ISSN: 2771-2214
Published Article

Digital Copyright Management Systems: Comparative Legal Analysis of Uzbekistan And Selected Foreign Jurisdictions

Digital Copyright Management Systems: Comparative Legal Analysis of Uzbekistan And Selected Foreign Jurisdictions

  • Abdumalikov Sharof Mirzaxid o‘g‘li
    Independent Researcher, Uzbekistan
Copyright digital copyright management electronic registration

The rapid expansion of digital content has fundamentally changed the way copyright works are created, distributed, licensed and monetized. Traditional copyright administration mechanisms, which were largely designed around identifiable physical copies and territorially limited markets, are increasingly challenged by online dissemination, user-generated content, streaming services, digital platforms and cross-border exploitation of creative works. In this environment, digital copyright management systems are becoming an important institutional and technological instrument for identifying works and right holders, documenting rights, facilitating licensing, monitoring uses and distributing remuneration.

This article examines the legal foundations and institutional models of digital copyright management in Uzbekistan in comparison with selected foreign jurisdictions, particularly the European Union, the United States and the United Kingdom. The study focuses not only on substantive copyright protection, but also on the administrative and technological mechanisms through which copyright is managed in the digital environment. Particular attention is paid to electronic registration and evidence systems, collective rights management, online licensing, rights information, notice-and-takedown procedures, transparency of royalty distribution and the role of public authorities.

The analysis demonstrates that Uzbekistan has established a general legal framework for copyright and related rights and has incorporated important international digital copyright standards through accession to the WIPO Copyright Treaty and the WIPO Performances and Phonograms Treaty. However, the existing framework does not yet provide an integrated digital infrastructure combining rights identification, registration, licensing, monitoring and remuneration distribution. Foreign experience shows that digital copyright management does not necessarily require a single centralized copyright register. Different legal systems employ different models: the United States combines voluntary electronic registration with platform-based enforcement mechanisms; the European Union emphasizes transparency, collective management and multi-territorial licensing; while the United Kingdom relies primarily on automatic copyright protection and specialized licensing and collective management mechanisms.

The article proposes a functional model for Uzbekistan based on interoperability, voluntary digital registration, reliable rights metadata, electronic licensing, transparent royalty accounting and institutional separation between public regulation and private rights management. Such a model could strengthen legal certainty without transforming registration into a constitutive condition for copyright protection.

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